Audit 389029

Food Distribution Cluster: Noncompliance over Procurement Condition: During our testing of procurement requirements, we noted that for one of the purchases selected there was no vendor selection form. The vendor selection form identifies the price and method selected. Without the form, the procurement documentation does not exist. Criteria: The Uniform Guidance (2 CFR 200.320) and the Organization’s procurement policy require that micro-purchases may be awarded without soliciting competitive quotations if the Organization considers the price to be reasonable and small purchases require price or rate quotations to be obtained from an adequate number of qualified sources. Cause: The exception was due to a breakdown in the Organization’s procedures to ensure that all procurements are in accordance with Uniform Guidance. Effect: Improper procurement procedures can result in actions taken by oversight agencies which could impact future funding. Context: The population subject to procurement requirements included 29 procurements. The sample size of five procurements was determined. Recommendation: We recommend that the Organization review and update its procedures to ensure that all procurements are in accordance with the Uniform Guidance and its procurement policy. Views of Responsible Officials: Management agrees with the finding.

Coronavirus State and Local Fiscal Recovery Funds: Noncompliance over Procurement Condition: During our testing of procurement requirements, we noted that for one of the purchases selected there was no vendor selection form. The vendor selection form identifies the price and method selected. Without the form, the procurement documentation does not exist. Criteria: Uniform Guidance (2 CFR 200.320) and the Organization’s procurement policy require that micro-purchases may be awarded without soliciting competitive quotations if the Organization considers the price to be reasonable and small purchases require price or rate quotations to be obtained from an adequate number of qualified sources. Cause: The exception was due to a breakdown in the Organization’s procedures to ensure that all procurements are in accordance with Uniform Guidance. Effect: Improper procurement procedures can result in actions taken by oversight agencies which could impact future funding. Context: The population subject to procurement requirements included three procurements. The sample size of two procurements was determined. Recommendation: We recommend that the Organization review and update its procedures to ensure that all procurements are in accordance with the Uniform Guidance and its procurement policy. Views of Responsible Officials: Management agrees with the finding.

Coronavirus State and Local Fiscal Recovery Funds: Noncompliance over Subrecipient Monitoring Condition: During our testing of subrecipient monitoring requirements, we noted that for all of the subrecipients tested, the Organization did not verify whether or not the subrecipient required and, if so, completed an audit. Criteria: 2 CFR 200.332(g) of the Uniform Guidance requires pass-through entities to verify that subrecipients are audited as required by subpart F of 2 CFR 200. Cause: The exception was due to a breakdown in the Organization’s procedures to ensure that all subrecipient monitoring procedures are in accordance with Uniform Guidance. Effect: There is an increased risk that noncompliance at the subrecipient level could occur and remain undetected by the Organization. Improper subrecipient monitoring procedures can also result in actions taken by oversight agencies which could impact future funding. Context: The population subject to subrecipient monitoring requirements included 69 subrecipients. The sample size of seven subrecipients was determined. Recommendation: We recommend that the Organization implement procedures that include monitoring that subrecipients needing an audit meet the requirement. Views of Responsible Officials: Management agrees with the finding.

Coronavirus State and Local Fiscal Recovery Funds: Material Weakness in Internal Control Over Reporting Condition: During our testing of reporting requirements, we noted that the Organization did not have adequate internal controls established to ensure the submission of complete and accurate required reports. We noted that reports were prepared by one individual without supervisory review or approval, and no other adequate internal control could be identified. Criteria: The Uniform Guidance (2 CFR 200.303) requires entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award. Cause: Management has not established procedures requiring review of reports prior to submission. Effect: As a result of the lack of internal controls over reporting, reports may be submitted with inaccurate information. Although no noncompliance was identified, this lack of internal controls increased the risk of inaccuracies not being detected and corrected. Context: The population subject to reporting requirements included one report. The sample size of one report was determined. Recommendation: We recommend that management implement internal control procedures over reporting, including supervisory review and approval of reports prior to submission. Views of Responsible Officials: Management agrees with the finding.